Effective Date: May 27, 2011
Rearden Commerce and its subsidiaries and affiliates (collectively, "Rearden Commerce") respect your privacy concerns. This Global Privacy Statement ("Privacy Statement") informs you of our privacy practices. The Privacy Statement applies to all Rearden Commerce-owned websites and domains (including www.deem.com and blog.deem.com) and the websites and domains of our wholly-owned subsidiaries, including Ketera Technologies (www.ketera.com), ExpenseWire (www.expensewire.com) and Global Ground Automation (www.globalground.com).
The goal of this Privacy Statement is to enable you to make informed choices regarding disclosing your personal information to us in connection with visiting our websites or using our products and services. This Privacy Statement explains:
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.
We may obtain personal information about consumers from various sources, such as:
The types of personal information we may obtain include:
In addition, when you visit Rearden Commerce websites or use our mobile applications, we may collect certain information by automated means, such as cookies and web beacons. A "cookie" is a text file that websites send to a visitor's computer or other Internet-connected device to uniquely identify the visitor's browser or to store information or settings in the browser. A "web beacon," also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We also may use third-party website analytics tools (such as Google Analytics and Omniture) that collect information about visitor traffic on our sites. The information we may collect by automated means includes:
Some of the information you may choose to provide in connection with using Rearden Commerce products and services may be deemed "sensitive" in the country in which you are located. For example, details regarding your air travel meal preferences or wheel chair requirements may be deemed sensitive in the European Union. Your provision of sensitive personal information about you to us is always voluntary. Rearden Commerce does not require you to provide sensitive information as a condition of obtaining our products or services. We use and disclose sensitive information only to provide the products andservices you request and as otherwise required or permitted by law.
We may use the information we obtain about you to:
We may combine the information we collect with publicly available information and information we receive from our parent, affiliate or subsidiary companies, business partners and other third parties. We may use that combined information to enhance and personalize your shopping experience with us, to communicate with you about products, services and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Statement.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
We do not sell or otherwise disclose personal information about you except as described in this Privacy Statement.
We may share the information we collect with:
We share the information only for the purposes described in this Privacy Statement, including to communicate with you about products, services, offers, events and promotions that we believe may be of interest to you. Our service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Employers and financial institutions that offer our products and services, merchants, and other third parties with which we share personal information may have their own privacy practices and privacy notices. Rearden Commerce is not responsible for those third parties' privacy practices. As described below, we offer you certain choices regarding how we share information about you.
In certain circumstances, we also may disclose information about you without obtaining your consent or offering you an opportunity to opt out. We may do so (i) if we are required to do so or believe to be required to do so by law, regulation or legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent or defend against misuse of Rearden Commerce services, violation of our intellectual property rights, breach of any of your or our business customers' obligations to Rearden Commerce, physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity.
We also reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets. Should such a sale, merger or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Statement. Following such a sale, merger or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you. Here are the choices we offer.
Many of the Rearden Commerce products and services are designed to facilitate and enhance consumers' ability to interact with and obtain products and services from third parties. This business model requires Rearden Commerce to share information about you with various providers (such as airlines, hotels, restaurants, car services and reservation aggregators) and other third parties. These third parties are not our service providers or agents; they may process the personal information we provide to them in accordance with their own privacy practices and privacy notices. You may choose not to provide your personal information to Rearden Commerce or such third parties by refraining from using our products or services. To deactivate your account, you may email us at firstname.lastname@example.org. If you are using Rearden Commerce products or services that a Rearden Commerce business customer (such as your employer or financial institution) obtained on your behalf, you must contact the relevant business customer to deactivate your account.
If your employer, financial institution or another Rearden Commerce business customer provides your personal information to us, you may have certain choices with respect to our use or disclosure of the information. Please contact the relevant Rearden Commerce business customer to learn about and amend your choices.
You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails or by adjusting your email preferences using the online account you may establish on our sites.
You may opt out of the aggregation and analysis of data collected about you on our sites by our web analytics vendors as follows:
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our sites' features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.
If you are a California resident, you may request that we provide to you (i) a list of the categories of personal information about you that Rearden Commerce has disclosed to third parties for the third parties' direct marketing purposes during the calendar year preceding your request, (ii) the names and addresses of such third parties, and (iii) if the nature of the third parties' business cannot reasonably be determined from their names, examples of the products or services marketed, if known to Rearden Commerce, that are sufficient to give you a reasonable indication of the nature of the third parties' business. To submit your request, please email email@example.com.
Subject to applicable law in the country where you are located, you may have the right to direct us not to share your personal information with third parties, except (i) with service providers we have retained to perform services on our behalf or (ii) as indicated in the "Required Disclosures" section of this Privacy Statement. To submit your request, please email firstname.lastname@example.org. In some circumstances, withdrawing your consent to Rearden Commerce's use or disclosure of your personal information will mean that you cannot take advantage of Rearden Commerce products or services.
To update your privacy preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.
You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information by logging into the online account you may establish on our websites.
In addition, if you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the "How to Contact Us" section of this Privacy Statement. If we deny an access request, we will notify you of the reasons for the denial. If you are using Rearden Commerce products or services that a Rearden Commerce business customer (such your employer or financial institution) obtained on your behalf, you should request such further access to your information from the relevant business customer.
Subject to applicable law, you may have certain additional rights to request access to and receive information about the personal information we maintain about you, update and correct inaccuracies in your personal data, and have the information blocked or deleted, as appropriate.
We may also provide social media features on our website that enable you to share Rearden Commerce information with your social networks and to interact with Rearden Commerce on various social media sites. Your use of these features may result in the collection or sharing of information about you. We encourage you to review the privacy policies and settings on the social media sites with which you interact to help you understand those sites' privacy practices.
When we obtain personal information about you, we may process the information outside of the country in which you are located, including in the United States. The countries in which we process the information may not have the same data protection laws as the country in which you are located. We will protect your information as described in this Privacy Statement.
We use commercially reasonable efforts to safeguard the confidentiality of your personal information, including the use of encryption, firewalls and Secure Socket Layers. To help safeguard personal information against loss and unauthorized access, we employ many different security techniques, including, for example, regulating the physical and virtual access to our databases, servers, back-ups, encryption keys or other network and security-related infrastructure components. In addition, we encrypt certain information, such as password and credit card numbers, in storage.
Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
In the ordinary course of business, Rearden Commerce retains information about you for the purposes described in this Privacy Statement as long as you maintain an active account. We also may retain certain personal information associated with a deactivated account for an additional period (normally at least one year and not longer than 7 years) at your request or to comply with technical, legal, data integrity, fraud prevention and financial reporting requirements.
When you visit our Career Center website, we may collect information such as the user name and password you select to establish an account on the site, your employment and education history and other personal information typically collected during the job application process. We use the information to enable you to search and apply for career opportunities at Rearden Commerce, submit your resume for general consideration, email a friend about this the Career Center, and comply with applicable legal requirements and our policies and procedures.
Rearden Commerce does not knowingly collect information from children under the age of 13 and does not target its websites to children under 13. If we learn that a user is under 13 years of age, we will promptly delete any personal information that the individual has provided to us. We encourage parents and guardians to take an active role in their children's online activities and interests.
This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Statement and indicate at the bottom of the notice when it was most recently updated.
If you have any questions or comments about this Privacy Statement, or if you would like us to update the information we have about you or your preferences, please contact us by email at email@example.com. You also may write to us at:
Attn: Chief Legal Officer – Privacy
1051 E. Hillsdale Blvd., Sixth Floor
Foster City, CA 94404